ML12130A044

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Summary of Public Meeting with Exelon Generation Company, LLC, Regarding Proposed Extended Power Uprate License Amendment Request for LaSalle County Station, Units 1 and 2
ML12130A044
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 06/07/2012
From: Nicholas Difrancesco
Plant Licensing Branch III
To:
DiFrancesco N
References
TAC ME7495, TAC ME7496
Download: ML12130A044 (27)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 7, 2012 LICENSEE: Exelon Generation Company, LLC FACILITY: LaSalle County Station, Units 1 and 2

SUBJECT:

SUMMARY

OF APRIL 4,2012, PUBLIC MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING THE PROPOSED EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST FOR LASALLE COUNTY STATION, UNITS 1 AND 2 (TAC NOS. ME7495 AND ME7496)

On April 4, 2012, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (EGC, the licensee) at the NRC Headquarters, Two White Flint North, 11545 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss a planned Extended Power Uprate (EPU) licensee amendment requested (LAR) for LaSalle County Station, Units 1 and 2 (LaSalle). A list of attendees is provided as Enclosure 1 .

During the meeting, EGC informed the NRC staff of their plans to submit an LAR, requesting a 12.5 percent increase in licensed thermal power for LaSalle in September 2012. The meeting discussion focused on concurrent calculated peak containment internal accident pressure (Pa) changes, alternate source term (AST) radiological analysis, and technical specification setpoint calculation changes. The licensee presented slides contained in Enclosure 2 and discussed a pre-application checklist contained in the public meeting notice (Agencywide Documents Access and Management System (ADAMS) Accession No. ML120750572).

The meeting piloted the use of the Nuclear Energy Institute (NEI) developed pre-application checklist. The purpose of the pre-application meeting using the NEI checklist is for NRC staff and licensees to reach common understanding of the regulatory criteria and standards to be applied in the review of significant licensing actions with a goal of enhancing the effectiveness and efficiency of the review process. A series of LaSalle EPU pre-application meetings are progressing for additional technical area topics. It is planned that for each subsequent pre application meeting, the NEI checklist will be used to support discussions. Additional information about the NEI checklist pilot process may be found in public meeting summary from November 2,2012 (ADAMS) Accession No. ML113210594).

No regulatory decisions were made during this meeting, although the following items were gener.::::y agreed to between the NRC and EGC, prior to submission of the LaSalle EPU LAR.

Summary of Follow-up Actions

1. EGC and the NRC staff agree in principle that the planned changes to the Technical Specification [TS] Allowable Values of Reactor Protection System and Primary Containment Isolation Instrumentation with EPU may be acceptable provided that the application is consistent with Title 10 of the Code of Federal Regulations (10 CFR) 50.36, "Technical specifications," Regulatory Guide (RG) 1.105, Revision 3, "Setpoints for Safety-Related Instrumentation," Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position on the Requirements of 10 CFR 50.36, "Technical Specifications,"

-2 Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels," NUREG-0800, "Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 7, "Instrumentation and Controls," and Branch Technical Position (BTP) 7-12, "Guidance on Establishing and Maintaining Setpoints." The NRC staff will evaluate consistence with the applicable regulatory criteria when the EPU

. application is received.

2.. EGC and the NRC staff agree in principle that the Analytical Limit (AL) for Average Power Range Monitor (APRM) Flow Biased Simulated Thermal Power Upscale Scram and Main Steam Line High Flow Group I Isolation will change with EPU. EGC stated that the new Allowable Value, Limiting Trip Setpoint, Nominal Trip Setpoints, As-Left Tolerance (AL T) and As-Found Tolerance are determined for each AL T using the EGC Setpoint Methodology NES-EIC-20.04, "Analysis of Instrument Channel Setpoint Error and Instrument Loop Accuracy," Revision 6. The EGC stated that the NES-EIC-20.04 Revision 6, licensee's methodology addresses the criteria in RG 1.105, Revision 3, RIS 2006-17, and TSTF-493, "Clarify Application of Setpoint Methodology for Limiting Safety System Settings," Revision 4, Option A. The staff requested that NES-EIC-20.04, Revision 6, be included in the EPU submittal. The staff also requested that two examples of setpoint calculations (e.g., APRM High Flux, Main Steam Line High Flow) be included with the EPU submittal to verify that the proposed amendment is indeed consistent with applicable guidance. The staff will conduct the regulatory review to evaluate consistence with the applicable regulatory criteria when the EPU application is received which also includes NUREG-0800, Chapter 7, BTP 7-12, and the regulations in 10 CFR Part 50.36.

3. EGC proposed to develop and submit a LAR for TS 5.5.13, revising Containment Pa for both current plant conditions and EPU conditions by submitting an LAR prior to their EPU LAR. Following the meeting, NRC staff concluded that EGC's approach may not be considered a linked review during the staff's acceptance of the EPU LAR provided that amendment revising TS 5.5.13 is found acceptable for NRC review under LlC-109, "Acceptance Review Procedures."
4. EGC and the NRC staff agree in principle that the revised AST Radiological Consequence Analyses with EPU has considered the applicable regulatory criteria and follow regulatory guidelines.
5. The NRC staff recommended that all parameters and assumptions used in the revised radiological dose consequence analyses supporting the application be listed in a table.

The NRC staff also recommended that the table contain the current licensing basis (CLB) values, the revised values, as well as, the basis for any changes to the CLB and consistency with regulatory guidelines.

6. The NRC staff suggested that future presentation topics address all proposed TSs, a list of all plant modifications required for EPU approval, and a list of all planned 10 CFR 50.59 evaluations supporting EPU implementation to allow for NRC inspection coordination. Ultimate heat sink was also suggested for a future presentation topic by both EGC and NRC staff.
7. The NRC staff suggested that the description of major modifications contained in the application include a brief description of industry precedence.

- 3

8. EGC informed the NRC staff that implementation of the EPU will rely on existing analog power range neutron monitors after approval. Approval will not be dependent on the planned application requests relating to digital instrumentation and control upgrades for power range neutron monitors or maximum extended load line limit analysis plus discussed during an April 5, 2012, public meeting (ADAMS Accession No. ML12137A209).
9. NRC requested EGC to coordinate exchange of generic data to allow for confirmatory analysis of the annual pressurization analysis presented during the prior December 7, 2011, pre-application meeting (ADAMS Accession No. ML120030321). NRC informed EGC that confirmatory models require significant time to develop a working model and benchmark the licensee's analyses. Preliminary modeling information would be needed prior to EPU submittal which would include TRACG computer input files or excel input tables information (e.g., mass and energy release information, vessel and containment structure geometric information).
10. The NRC staff requested that EGC discuss LaSalle's reactor core thermal hydraulic stability monitoring analysis. Given that LaSalle, Unit 2, previously experienced a power oscillation in March 1988, the staff will focus on how the changes in the core loading strategies will affect stability under EPU conditions. The EGC should also demonstrate that anticipated transient without scram stability mitigating actions remain effectively under the EPU conditions.

The meeting notice and agenda are available under ADAMS Accession No. ML120750572.

The public was invited to observe the meeting. Several members of the public were in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-1115, or Nicholas.DiFrancesco@nrc.gov.

~h~

Nicholas DiFrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosures:

1. List of Attendees
2. Licensee Handouts cc w/encl: Distribution via ListServ

LIST OF ATTENDEES APRIL 4, 2012, PUBLIC MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING THE PROPOSED EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST FOR LASALLE COUNTY STATION, UNITS 1 AND 2 NRC J. Zimmerman N. DiFrancesco W.Jessup J. Huang D. Rahn Public T. Huang J. Keys - NEI A. Sallman J. Fields - Xcel Energy G. Armstrong D. Anderson - Westinghouse*

B. Dittman E. Chu - Westinghouse*

J. Parillo V. Kumar - Westinghouse*

D. Duvigneaud EGC K. Bolton J. Rommel K. Ainger V. Shah F. Pournia K. Barnes D. Neff T. Simpkin J. Krejcie R. Janowiak B. Maurer - Westinghouse E. Schrull - GEH S. DuPont C. Lambert

  • M. Lohman
  • S. Rudy - GEH*

J. Creech - GEH*

  • via teleconference Enclosure 1

Exelon.

Nuclear LaSalle County Station Pre-Application Meeting Extended Power Uprate April 4, 2012 Enclosure 2

Introductions

  • Kenneth Ainger - Project Management Director, EPU

Nuclear

Agenda and Meeting Purpose

  • Describe Key Aspects of Technical Evaluations
  • Concurrent Pa Change
  • Technical Specification Setpoint Calculations
  • Planned Major Modifications
  • Update on Steam Dryer Evaluation
  • NEI Checklist Critique Exelon.

Nuclear

NEI Pilot - Pre-submittal Meetings Purpose is to enhance License Amendment Request pre-submittal meetings

  • Reach a common understanding on the regulatory criteria and standards to be applied during the NRC review of the proposed changes
  • Identify potential application issues that can be addressed during the application conceptual phase that will reduce acceptance review time, requests for additional Information, and application review time Process
  • Pilot Checklist is used to focus on applicable review criteria, codes, standards, justification required for use of a new analytical method, applicability of a precedent, or feasibility of a desired schedule in order to reach alignment with the NRC
  • NRC meeting notice and meeting summary will docket the expectations and outcomes of the alignment in order to greatly reduce the risk and uncertainty associated with future application acceptance and NRC review LaSalle specific checklist focus - Technical Issues
  • Concurrent Pa Change
  • Technical Specification Setpoint Calculations Exelon.

Nuclear

Schedule Overview EPU Projected Power Uprate level of 3988 MWt (increase -12.5% of current licensed power or 1200/0 of original licensed power)

EPU Implementation Schedule

  • Submit LAR: Target September 2012
  • LAR Approval: Target May 2014
  • Unit 2 Implementation: February 2015 (Outage L2R15)
  • Unit 1 Implementation: February 2016 (Outage L 1R16)

Exelon.

Nuclear

Concurrent Calculated Peak Containment Internal Accident Pressure (Pa) Change Kevin Borton Exelon.

Nuclear

Concurrent P _ Chanae

Purpose:

Reach an understanding that a separate Pa current power level change would not be linked to the proposed EPU related Pa change

Background:

  • EPU LAR will include a request to increase Pa
  • LaSalle identified a current calculated Technical Specification Pa issue that requires a Pa increase
  • Issue entered in LaSalle Corrective Action Program

- Operability Evaluation in place to address issue Exelon.

Nuclear

Concurrent P Chanae ofIl LIC-109 Guidance

  • Current issue requires Pa value increase
  • EPU power level requires Pa value increase beyond current issue required increase
  • Assumptions and methods regarding current power level and EPU power levels are the same
  • Although the proposed changes are prepared and reviewed the same, the current issue and the EPU LAR are not contingent upon the approval of the other
  • Multiple LARs can affect the same systems or Technical Specifications (TS) without being linked
  • LIC-109 guidance supports concurrent NRC reviews Exelon.

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AST Radiological Analyses Purpose Discuss LaSalle's planned approach for AST analyses Methodology

  • Used Regulatory Guide (RG) 1.183 Rev. 0, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000
  • Started with existing approved AST analyses and modified for EPU core source term and power level

- RADTRAD re-run

- AST analyses performed for Main Steam Line Break Accident (MSLBA) and Control Rod Drop Accident (CRDA) consistent with RG 1.183 section 1.1.3 guidance

  • All regulatory dose limits specified in 10 CFR 50.67 are met ~h E~U l:Xelon.

Nuclear

AST Radiological Analyses

  • Analyses performed using EPU core inventory and AST for

- LOCA

- FHA

- MSLBA

- CRDA

  • Analyses are consistent with previously approved AST analyses with changes as necessary for EPU

- Core inventory, power level, post-LOCA temperatures

  • RG 1.183 Revision 0 criteria met Exelon.

Nuclear

AST Radiological Analyses Draft Results

  • All analyses re-performed meet applicable limits with EPU
  • No revision to input parameters required to meet regulatory limits with EPU DRAFT LOCA Radiological Consequences TEDE Dose (REM)

Receptor Location CR EAB LPZ Calculated Dose CLTP 4.27 2.59 0.27 Calculated Dose EPU 4.70 2.91 0.31 I I

Allowable TEDE Umit 5.0 25.0 25.0 Exelon.

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Technical Specification Setpoint Changes

Purpose:

Obtain an agreement that the LaSalle's methodology and approach to Instrument Setpoint Changes is appropriate Methodology

  • Current - Exelon Setpoint Methodology (NES-EIC-20.04 < Rev 5)

- Methodology through Rev 4 was reviewed with the Improved Technical Specification Conversion

  • EPU - Exelon Setpoint Methodology (NES-EIC-20.04 > Rev 6)

Conformance with NRC Guidance

  • Current Basis (NES-EIC-20.04 Rev 5 or earlier)
  • New Technical Specification Setpoints - TSTF-493 Rev 4 Option A Implemented in NES-EIC-20.04 Rev 6 Exelon.

Nuclear

Technical Specification Setpoint Changes Comparison of CLTP to Proposed EPU Technical Specification (TS) Setpoint Changes ClTP Value EPU Value TSAV NTSP TSAV NTSP APRM Flow Biased STP So 0.61W + 6B.2 & 0.61W + 62.6 & So 0.55W + 63.5 & 0.55W + 57.4 &

Upscale Scram* TlO < 115.5 % 113.5 % < 118.0% 113.3%

APRM Flow Biased STP So O.54W + 55.9 & O.54W + 50.5 & So O.4BW + 49.6 & 0.48W + 43.6 &

Upscale Scram - SlO S. 112.3 % 10B.1 0/0 So 112.3 % 107.6 %

APRM Flow Biased STP

.:S 0.61W + 56.9 0.61W + 51.3 .:S 0.5SW + 52.2 O.SSW +46.6 Upscale Rod Block - TlO APRM Flow Biased STP So O.54W + 44.7 O.54W + 39.2 So O.48W + 39.5 0.48W +39.1 Upscale Rod Block* TlO APRM Neutron Flux-High,

.:S 20.0 % 15.0 % .:S 22.6 % 17.B%

Setdown Scram APRM Neutron Flux-High,

.:S 14.0 % 12.0 % .:S 16.6 % 12.3%

Setdown Rod Block Main Steam line Flow High Primary Containment .:S 128 psid 125 psid .:S 197.3 psid 188.B psid Isolation Turbine Trip Scrams

~ 25% RTP 104.1 psig ~ 23% RTP TBD Permissive Rod Worth Minimizer

.:S 10% RTP 14.2 % RTP So 10% RTP 14.4 % RTP low Power Setpoint Exelon.

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Planned Major Modifications

  • High Pressure Turbine Upgrade
  • Main Generator Upgrade
  • Condensate Pump Upgrade
  • Condensate Polisher System Upgrade
  • Reactor Water Level Control System
  • Addition ot runback logic on trip ot
  • Isophase Bus Duct Upgrade Condensate Pump
  • Steam Dryer Replacement induced vibration monitoring
  • Several balance-ot-plant setpoint and scaling changes Exelone Nuclear

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Update on Steam Dryer Evaluation

Purpose:

Provide update on steam dryer replacement decision and schedule The Exelon Licensing Apl?roach will be provided during the Peach Bottom Pre submittal Meeting on April 5 Decision:

Analyzed current steam dryers:

  • Evaluated necessary modifications
  • Decided to proceed with replacement dryer Proceeding with Westinghouse Replacement Steam Dryers (RSD)

RSD Schedule:

RSD driving EPU submittal date Installation sequence is:

  • LaSalle County Unit 2: February 2015 (Outage L2R15)
  • LaSalle County Unit 1: February 2016 (Outage L1R16)

Exelon.

Nuclear

Acronym List

  • ACM - Acoustic Circuit Model
  • APRM - Average Power Range Monitor
  • AV - Allowable Value
  • CLTP - Current Licensed Thermal Power
  • CR - Control Room
  • DBA - Design Basis Accident
  • EAB - Exclusion Area Boundary
  • FHA - Fuel handling Accident
  • LAR - License Amendment Request
  • LOCA - Loss-of-coolant Accident
  • LPZ - Low Population Zone
  • MWt - Mega Watts thermal
  • NEI - Nuclear Energy Institute
  • NTSP - Nominal Trip Setpoint
  • Pa - The calculated peak containment internal pressure related to the design basis accident
  • RG - Regulatory Guide
  • SLO - Single Loop Operation
  • STP - Simulated Thermal Power
  • TEDE - Total Effective Dose Equivalent
  • TLO - Two Loop Operation
  • TS - Technical Specification
  • TSTF - Technical Specification Task Force Exelon.

Nuclear

Future EPU Meeting Topics and Schedule

  • Follow-up EPU Meetings
  • Proposed Topics

- Human Factors

- Technical Specifications

- Ultimate Heat Sink

  • Next meeting target July 2012 Exelon.

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8. EGC informed the NRC staff that implementation of the EPU will rely on existing analog power range neutron monitors after approval. Approval will not be dependent on the planned application requests relating to digital instrumentation and control upgrades for power range neutron monitors or maximum extended load line limit analysis plus discussed during an April 5, 2012, public meeting (ADAMS Accession No. ML12137A209).
9. NRC requested EGC to coordinate exchange of generic data to allow for confirmatory analysis of the annual pressurization analysis presented during the prior December 7, 2011, pre-application meeting (ADAMS Accession No. ML120030321). NRC informed EGC that confirmatory models require significant time to develop a working model and benchmark the licensee's analyses. Preliminary modeling information would be needed prior to EPU submittal which would include TRACG computer input files or excel input tables information (e.g., mass and energy release information, vessel and containment structure geometric information).
10. The NRC staff requested discussion of LaSalle's reactor core thermal hydraulic stability monitoring analysis. Given that LaSalle, Unit 2, previously experienced a power oscillation in March 1988, the staff will focus on how the changes in the core loading strategies provide will affect stablJity under EPU conditions. The EGC should also demonstrate that anticipated transient without scram stability mitigating actions remain effectively under the EPU conditions.

The meeting notice and agenda are available under ADAMS Accession No, ML120750572.

The public was invited to observe the meeting. Several members of the public were in attendance. Public Meeting Feedback forms were not received, Please direct any inquiries to me at 301-415-1115, or Nicholas.DiFrancesco@nrc.gov.

Sincerely, I RAI Nicholas DiFrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos, 50-373 and 50-374

Enclosures:

1, List of Attendees 2, Licensee Handouts cc w/encl: Distribution via ListServ RiasNrrPMLasalie Resource John Rill LPL3*2 RiF RiOsOgcMailCenter Resource David Rill RldsNrrAoro Resource RldsOpaMail Resource RidsNrrDoll Resource R,dsRgn3MailCenter Resource RiosNrrOorlLpl3-2 Resource [Name] EOO Region X Accession Number;Package; ML12130A49, Meeting Summa wi enclosure 1;ML12130A044, Enclosure 2: ML120930616 CE ~~:~~::~! PM ~~:hL:~;L3'2iLA ~~;~~;~:~2/BC .;;;.,~:-,,~,-/P....._

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